Sanctioned but Thriving: How Online Platforms Fail To Address the Widespread Presence of Entities Under EU Sanctions
The report was created with cases contributed by Alliance4Europe, Science Feedback, Logically Facts, Alliance for Securing Democracy – German Marshall Fund, Prose Intelligence, Democracy Reporting International, Södertörn University, and the Italian Federation for Human Rights (FIDU).
This collaboration was made possible through the Counter Disinformation Network (CDN), a collaborative platform of over 150 practitioners from 30+ organizations, convened by Alliance4Europe to protect European democracy and coordinate efforts against information manipulation.
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Executive summary
In the wake of the Russian invasion of Ukraine, the EU adopted sanctions on Russian and Belarussian actors supporting the war. The list of sanctioned actors includes a number of state-controlled media as well as what the European Commission described as prominent individual propagandists, making it illegal to host or broadcast their content to EU audiences, including on social media platforms.
In the summer of 2024, a series of 5 reports documented how, despite this EU prohibition, many high-profile sanctioned media entities and individuals maintained an EU-accessible presence on Meta services, Google services, X/Twitter, TikTok and Telegram. Illegal content from these sanctioned entities was further amplified by unaffiliated accounts resharing content, for ideological or economic reasons. The accounts documented had a significant influence, garnering a combined total of over 20 million followers, many of them within the EU.
Platforms were made aware of both the systematic nature of this phenomenon and of certain specific suspected violations of EU law. The present report aims at tracking the extent to which platforms have tackled the issue, in compliance with both the Digital Services Act (DSA) as well as EU and Member States’ sanctions legislation.
We find that:
- Across platforms other than TikTok (which acted on all flags), 83% of the accounts of sanctioned entities or individuals reported remain accessible in the EU, in what appears to be a contradiction with the EU sanctions regime. In addition, 48% of the unofficial amplifiers of sanctioned content remained EU-accessible and kept on posting such content (with a further 24% having sanctioned content in their history but not posting new ones). These remaining channels have approximately 13.5 million followers.
- Across platforms, further searches yielded 370 previously unreported new cases of official accounts of sanctioned entities or amplifiers of content created by sanctioned entities being accessible in the EU. They also uncovered new sanctions-evading behaviours and types of actors, suggesting that the issue is pervasive and that platforms’ potential efforts to combat it are falling short. These platforms’ success in tackling copyright infringement, another type of illegal content, suggests that technical solutions do exist to ensure at-scale compliance. These newly identified pages have over 23 million followers.
- On Belarussian-sanctioned entities and individuals, we find that the most prominent sanctioned state-owned media channels have an official, unhindered EU presence across platforms. 90 likely violations were found across these platforms. These pages have over 3.8 million followers in total.
- Many amplifier accounts, as well as a number of officially sanctioned accounts, appear to benefit from some platforms’ monetization programs, notably ad-revenue sharing (Telegram, YouTube) or subscription (Facebook). This monetization is possibly creating an opportunity for illicit groups to find alternative financing.
These findings and figures are conservative estimates, as they consider only the accounts and behaviours we were able to observe using limited means and do not exhaustively cover all instances of EU sanctions violations nor do they cover the entire range of different services offered by these companies (email, cloud hosting, private messaging…).
Overall, given the ease with which such illegal content was discovered, Meta, Google, X/Twitter, TikTok and Telegram’s compliance teams should investigate why they seem not to have taken sufficient action to limit access.
These findings raise three questions in the EU regulatory context:
- Whether the extent to which these services acted on notices of EU illegal content meets the standards set out in the DSA,
- Whether the extent to which these services prevent the dissemination of illegal content meets the risk mitigation obligations set out in the DSA (Articles 34 and 35),
- Whether these services provide economic resources to sanctioned entities, in possible contradiction with EU sanctions regulations (Art. 2 of Council Regulations No 269/2014 and No 765/2006) and their transposition at the Member State level.
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